Small business financers and brokers (“providers”) active in New York are officially on notice to finalize their preparations to comply with New York’s Commercial Finance Disclosure Law (“CFDL”) by August 1, 2023, the new...more
Small business lenders hoping for federal intervention will be disappointed to learn that the Consumer Financial Protection Bureau (CFPB) has reached a preliminary determination that New York’s new commercial financing...more
1/6/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financing ,
Lenders ,
Preemption ,
Small Business ,
Small Business Loans ,
Truth in Lending Act (TILA)
While many around the world are setting their calendars forward for the year 2023, residential mortgage loan owners and servicers may need to also look backward in time now that New York Governor Kathy Hochul signed the...more
Utah has followed California and New York by enacting its own Truth in Lending-like commercial financing disclosure law, but with an additional twist—Utah’s new law has a registration requirement. On March 24, Utah Governor...more
Marketplace lender Opportunity Financial, LLC (“OppFi”) has gone on the offensive against the California Department of Financial Protection and Innovation (“DFPI”) to protect its bank partnership program against challenge on...more
The New York Department of Financial Services (NYDFS) has issued “pre-proposed” rules under New York’s commercial financing disclosure law that was enacted at the end of 2020. The pre-proposed rules are 45 pages in length...more
As expected, New York has broadened the reach of its new commercial financing disclosure law less than two months after its enactment. S.B. 5470, as previously reported by Mayer Brown, imposed a range of Truth in Lending-like...more
In late December 2020, New York Governor Andrew Cuomo signed S.B. 5470 into law, which will impose a range of Truth in Lending Act-like disclosure requirements on providers of commercial financing in amounts of $500,000 or...more
The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more
12/9/2020
/ Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Financial Regulatory Reform ,
GSE ,
Infectious Diseases ,
Inter-Bank Offered Rates (IBORs) ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Structured Finance ,
UK Brexit ,
Volcker Rule
In recent weeks, the US federal housing agencies and government-sponsored enterprises (GSEs) that insure, guarantee, or purchase “federally backed mortgage loans” covered by Section 4022 of the CARES Act (Act) have continued...more
6/24/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Federal Housing Administration (FHA) ,
FHFA ,
Financial Distress ,
Forbearance Agreements ,
Foreclosure ,
Freddie Mac ,
GSE ,
Housing Market ,
HUD ,
Moratorium ,
Mortgages ,
Relief Measures